Telehealth Policy |

Telehealth Policy

Medicare telehealth policy has shifted dramatically for the entire healthcare industry in response to COVID-19, both policy unique to RHCs and more broadly within the fee-for-service community.

Table 1 breaks down the types of telehealth services RHC can bill for and how to bill for, including what was billable during the COVID-19 Public Health Emergency and the services’ temporary or permanent status. The majority of telehealth waivers will require further legislative action if they are to remain permanent.

All RHCs billing for telehealth should review the MLN Matters document: New and Expanded Flexibilities for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) During the COVID-19 Public Health Emergency (PHE).

In December 2020 CMS announced significant telehealth coinsurance changes.

Beginning January 2022 and not connected to the PHE, RHCs can bill and be reimbursed for mental health services provided via telehealth. More information can be found here.

NARHC continues to advocate for permanent coverage of all telehealth services and a revision of the RHC/FQHC payment policy to ensure that RHCs do not experience a disparity in reimbursement as compared to their fee-for-service counterparts who receive payment parity.Table 2 highlights the various Medicare telehealth waivers and their current status as of fall 2023.

With any questions, please email Sarah Hohman at Sarah.Hohman@narhc.org.

Table 1

Name of Telehealth Service	Brief Description	How to Bill	Reimbursement Rate	Relevant Dates
Virtual Check-In or Virtual Care Communications	Remote evaluation - G2010 Brief communication with patient (5 min) - G2012	G0071 Bill on UB-04 No modifier necessary Rev Code 052X	2022: $23.88 2023: $23.72	Permanent coverage
Digital e-Visits	Online evaluation and management 99421-99423	G0071 Bill on UB-04 No modifier Rev Code 052X	2022: $23.88 2023: $23.72	Only billable during the COVID-19 PHE (ended May 11, 2023).
Telehealth Visits	One to one substitutes for in-person services/visits List of allowable services maintained by CMS (including services allowed via audio-only)	G2025 Bill on UB-04 Modifier 95 optional Modifier CS (for services where cost sharing is waived Rev Code 052X Costs and encounters carved out of cost report	2022: $97.24 2023: $98.27	Currently set to expire December 31, 2024
Mental Health Telehealth Visits	One to one substitutes for in-person mental health services/visits CPT codes that can be billed with 0900 revenue code	Rev Code 0900 Use proper mental health CPT code Modifier CG always Modifier 95 if audio-video Modifier FQ or 93 if audio-only Count costs and encounters on cost report	All-Inclusive Rates	Permanent coverage beginning January 1, 2022 *Occasional in-person visit requirement begin on January 1, 2025
Chronic Care Management/ Principal Care Management	99484, 99487, 99490, 99491, 99424, and 99425 = G0511 99492, 99493 = G0512	G0511- Care Management G0512- Psychiatric Care Management	G0511 2022- $79.25 G0511 2023- $77.94 G0512 2022- $151.23 G0512 2023- $146.73
Transitional Care Management	Supporting the additional work provided to patients following discharge from an acute care setting to prevent errors and readmissions.	99495, 99496 on an RHC claim, either alone or with other payable services	If it is the only medical service provided on that day with an RHC or FQHC practitioner it is paid as a stand-alone billable visit. If it is furnished on the same day as another visit, only one visit is paid.	Covered since January 1, 2013

Table 2

Medicare Policy Area	Current Policy and Duration of Flexibility/Waiver
Originating Site/Geographic Requirements	Patients can receive telehealth services in their home or anywhere else through December 31, 2024.
Distant Site Requirements	RHC providers can serve as telehealth distant site providers through December 31, 2024. RHC providers can offer telehealth services from any location, including their home, during this period.
Billing/Cost Reporting Requirements	Please see table above. G2025 policy for medical telehealth visits remains in effect through December 31, 2024.
Modality	The Office of Civil Rights allowed for “non-public facing” remote communication products to be used for telehealth services, “exercising discretion” on stringent HIPAA compliant platform requirements. This ended on May 11, 2023

Other Telehealth Information of Interest:

The Drug Enforcement Agency extended the flexibilities for prescribing controlled substances via telehealth through December 31, 2024.
HHS provided resources on educating patients on privacy and security risks when using telehealth.